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Policy for Scientific Review of Clinical Protocols Utilizing the NIH Intramural Program

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Policy for Scientific Review of Clinical Protocols Utilizing the NIH Intramural Program Policy for Scientific Review of Clinical Protocols Utilizing the NIH Intramural Program Submission Requirements and Review Criteria PURPOSE The purpose of this policy is to describe the minimum requirements for NIH Institutes and Centers (IC) to integrate policies related to clinical protocols into their intramural scientific review. DEFINITIONS AND SCOPE “Clinical protocol” means a document outlining human subjects studies requiring IRB approval. Clinical protocols may include clinical trials1, non-interventional observational (natural history) studies, screening protocols, repository protocols and teaching and training protocols. The scientific review process includes the initial protocol review, annual and quadrennial review of the ongoing protocol, and review of substantive amendments to the protocol that pose new scientific questions or substantially alter the scientific approach. In addition, the scientific review process includes prioritization of clinical protocols utilizing scarce resources at the NIH Clinical Center (CC) to assure the best science is being supported. These reviews become part of the official protocol record and are made available to the IRB and NIH leadership. The scientific review process includes assessment of resource requirements for the Clinical Center, as well as anticipated service needs from other ICs. If an IC wants to waive scientific review, the reasons for the waiver must be documented. IC leadership and the NIH Associate Director for Clinical Research/Chief Scientific Officer CC must sign off on the scientific review before protocols are sent for Institutional Review Board (IRB) review. Full scientific review is not the purview of NIH IRBs. However, should an IRB have concerns about the quality of the scientific review, or its absence, the Chair should speak with the IC Clinical Protocol Scientific Review Committee Chair (see below) to resolve these concerns prior to IRB review. The Process of Initial Scientific Review ICs are encouraged to conduct a protocol concept review via initial discussions by principal investigators (PIs) with their laboratory/branch chief, Clinical Director and/or Scientific Director, or central IC concept review committee for ICs that have such a committee. The purpose of concept review is to address feasibility, fit within the mission of the IC’s intramural division, availability of lab/branch resources and additional resources outside the lab/branch, and requirements for a CRADA or clinical trials agreement (CTA). Concept reviews can consider and modify objectives, design, eligibility, and statistical analysis. The concept review is not required in the official protocol record although notation of whether it occurred will be recorded on the NIH Scientific Review of Clinical Protocols form in the Integrated Research Information System (iRIS). 1 The NIH definition of a clinical trial is “A research study in which one or more human subjects are prospectively assigned to one or more interventions (which may include placebo or other control) to evaluate the effects of those interventions on health-related biomedical or behavioral outcomes.” [https://grants.nih.gov/policy/clinical- trials/definition.htm] ICs will conduct scientific review of complete protocols by a Scientific Review Committee within the office of the Clinical Director or Scientific Director. At an IC’s discretion, the Scientific Review Committee may include members from the protocol’s originating laboratory/branch. Other reviewers, who will not be members of the laboratory/branch from which the protocol originates, will include the chair and co-chair, at least two additional IRP reviewers, and a statistician. To avoid conflict of interest for protocols with the Lab or Branch chief, Clinical Director, Scientific Director or Institute Director as the principal investigator, a central IC office, or that of another IC, should perform the review. The Scientific Review Committee Chair may use ad hoc representatives from CC departments or consult services on the review committee. ICs may use external subject matter experts to enhance the scientific review, or the IC’s extramural staff with subject matter expertise . IC’s have discretion in the composition of the Scientific Review Committee as long as the appropriate expertise is included. If ICs elect to use external reviewers, appropriate clearance of conflict of interest for participation must be obtained using a recommended short certification form. Scientific reviews should be completed as expeditiously as possible, including initial review, response to stipulations and suggestions, and final approval. There should be an attempt to achieve consensus in all decisions. If the protocol is returned to the PI with stipulations, at the Chair’s discretion, the PI response can receive expedited review by the Chair or the committee could be reconvened for further discussion. ICs will provide a summary rating of the scientific review for each clinical protocol using verbal descriptors (Outstanding, Excellent, Good, Fair, Poor) or a numerical score (0=Poor, 10=Outstanding) (see Appendix 1- Guidelines for Reviewer Comments for Initial Scientific Review of Protocol). Records should be kept of the outcome of the scientific review process. For each IC’s intramural program documentation of what protocols were put forward, whether there was a concept review, whether the protocol went forward to a full protocol review, what were the results of the review (approved with or without stipulations, or not approved) and was the protocol re-reviewed after stipulations were met? The record, with dates for all the steps of the scientific review process, will be recorded by ICs on the standard NIH Scientific Review of Clinical Protocols form in the Integrated Research Information System (iRIS). Required Materials for Initial Scientific Review 1. Protocol Elements An NIH intramural clinical protocol must contain the following information to provide evidence that the investigator(s) has planned a feasible and scientifically excellent clinical study. General elements for all protocols include: • Official protocol title. • Study Population: A description of the study population, including the sample size, gender, age, demographic group, required health status, and geographic location. • Where study subjects will be seen. • If a multi-site study: o Clinical sites participating. o Describe governance of protocol and the coordinating center if one is planned. • Recruitment and plans: o Availability of potential participants, in compliance with NIH policy, as appropriate, for women and minorities and inclusion across the lifespan. o Ability of participating sites to recruit and retain the proposed target number of participants. 2 o Recruitment milestones over the duration of the study. • Resource availability: o For protocols with significant impact on the CC (e.g., ICU, cell processing, surgery) or on IC consult services, individuals from the CC departments and or IC consult services should provide written confirmation of resource availability. o For all protocols being conducted at the CC the Protocol Resource Impact Assessment (PRIA) must be completed and reviewed by the CC prior to Institutional Review Board (IRB) review. • Statistical analysis plan: A statistical justification pertinent to design and power calculations as a statistical analysis plan must be included (see section 7 below “Statistical Analysis Plan”). • Study Duration: Estimated time (in months) from when the study opens to enrollment until: (a) completion of data collection and (b) final data analyses. For Clinical trials: • Define phase of the clinical trial (phase 0-IV). • Describe the intervention to be tested: Interventions include drugs/small molecules/compounds; biologics; devices; procedures (e.g., surgical techniques); delivery systems (e.g., telemedicine, face- to-face interviews); strategies to change health-related behavior (e.g., diet, cognitive therapy, exercise, development of new habits); treatment strategies; prevention strategies; and diagnostic strategies. • If applicable, describe the dose, frequency, and route of administration of the intervention(s). • Describe methods used to assign participants to study groups (treatment arms) and randomization, if applicable. • Assure compliance with the “NIH Policy and Guidelines on The Inclusion of Women and Minorities as Subjects in Clinical Research and inclusion across the lifespan.” • Describe the procedures to be followed in each arm of the trial, if applicable. • Provide the availability of Investigational Product (IP), IND/IDE status and whether the investigators have had any interactions with the Food and Drug Administration (FDA). • Specify primary and important secondary endpoints: In a Clinical Trial, the primary endpoint is the pre-specified goal(s) or condition(s) that reflects the effect of one or more interventions on human subjects’ biomedical or behavioral status or quality of life. Examples include: positive or negative changes to physiological or biological parameters (e.g., improvement of lung capacity, gene expression); positive or negative changes to psychological or neurodevelopmental parameters (e.g., mood management intervention for smokers; reading comprehension and /or information retention); positive or negative changes to disease processes; positive or negative changes to health-related behaviors; and positive or negative changes to quality of life. • Describe preclinical data and replications and the level of attention
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